Wilson v. Commissioner of Social Security

Robert M. Wilson (plaintiff) was denied Social Security disability benefits following a hearing before an administrative-law judge (ALJ), who found that Wilson was not disabled before his last insured date of March 31, 1995. The ALJ’s decision summarily discredited the opinion of Wilson’s treating physician, who had treated Wilson during the relevant period and who opined that Wilson had greater limitations on his ability to work than those found by the ALJ. The ALJ did not provide any reasons for discrediting the opinion; in fact, he admitted that the opinion might be an accurate assessment of Wilson’s impairments. However, the ALJ found that as of the date Wilson was last insured, he was not disabled because he had the residual functional capacity to perform work existing in significant numbers within the national economy. The ALJ’s decision became the final decision of the Commissioner of the Social Security Administration (defendant). Wilson sought judicial review of the commissioner’s decision in a United States district court, requesting reversal of the decision due to the commissioner’s failure to follow his own regulations regarding treating physicians’ opinions. The district ruled in favor of the commissioner, although the treating physician’s opinion covered the relevant time period, finding that the failure to give the opinion controlling weight or to provide good reasons for not doing so constituted harmless error because the ALJ’s opinion was otherwise supported by substantial evidence. Wilson appealed.